Sophisticated Defense For IRS Examinations And Appeals
Preparing for an IRS examination is nerve-wracking. Flunking this high-stakes exam can mean you are on the hook for back taxes, penalties and interest (and possibly criminal prosecution). If you or your business have been targeted for audit, or if you dispute the findings of an examination, you can turn to Moore Tax Law Group, LLC, for guidance and advocacy.
We provide IRS examination defense to business owners and individuals as well as partnerships and other business entities in Illinois and nationwide. Our tax litigation attorneys also represent clients in IRS appeals to try to reach a resolution. Call our Chicago law office for proactive legal assistance.
We Have Your Back In IRS Examinations
We frequently assist clients with IRS examinations (audits) when the issues are complex or there is a great deal at stake. We can take the lead in managing interactions with the IRS examiners or stay backstage providing advice as needed. Our services include:
- Preparation for the interview (including whether to attend)
- Responding to Information Document Requests (IDRs)
- Examination defense
- Settlement negotiations
Our lawyers draw on years of experience defending clients to counsel them through the process and present their cases to the IRS in the most favorable light. Our goal is to resolve disputes at the examination level if possible.
IRS Appeals And U.S. Tax Court Litigation
When a taxpayer cannot resolve a disputed issue with the IRS examination team, we guide the taxpayer through the strategic decision of whether and when to take the issue to IRS appeals. We draft submissions to the appeals officers that include everything that would need to go into a memorandum finding in our favor, including effective explanations of the litigation risk faced by the IRS.
Having taken cases all the way through trial, we are well-equipped to defend the IRS exams and position clients for victory in appealing cases to Tax Court if we cannot reach a settlement at the administrative appeals level.
In-Depth Experience In Examinations
Moore Tax Law Group, LLC, assists with both correspondence examinations and face-to-face examinations (at an IRS field office or at your business). We have experience with every type of tax and every category of exam, including:
Partnership representation: Professional partnerships receive special scrutiny by the IRS under tax reforms enacted in 2015 (IRC 6223) and may be required to designate a legal representative. Learn more about our advocacy as professional partnership representatives in this evolving arena of federal taxation and our experience with IRS partnership examinations.
Information return penalty examinations: Failing to file correct and accurate forms when submitting tax returns or failure to file forms in a timely manner is flagged by the IRS as possible fraud. We represent individuals and businesses facing audits and potential penalties over information returns. Penalties are levied for each instance, meaning the fines would be multiplied if an error on W-2 forms were repeated across the business. We intervene to show that any mistakes were unintentional and that our client made a good faith effort to submit accurate forms or comply with IRS requests.
Material participation examinations: The IRS frequently examines real estate professionals in connection with the level of participation and ability to take certain deductions for real estate activities. We have successfully defended these exams at the IRS examination and IRS appeals levels by demonstrating that our clients in fact participated in the operations on a regular, continuous and substantial basis. We also prevailed in one such material participation case in Tax Court.
Take Control Of Your IRS Examination
The IRS examination process is daunting. You may feel that you are being unfairly accused or singled out. The attorneys of Moore Tax Law Group, LLC, are well-versed and highly experienced in defense. Our proactive approach and attention to detail put you in the best position for a timely and favorable resolution.